Before collecting any biometric identifier, have a publicly available retention and destruction policy, obtain informed written consent, and confirm your vendor contracts address BIPA compliance. Statutory damages for violation(s) are significant. 5. Document, escalate and be consistent. Set a clear protocol for when red flags appear: pause the deal, escalate to a manager, record the verification steps taken, and do not deliver until the issue is resolved. Apply that protocol uniformly to every customer. Consistent application supports fair lending compliance, and good documentation is your best evidence in a repurchase dispute. 6. Coordinate with lenders and authorities. Share any suspected fraud with your lending partners promptly, report it to law enforcement and your insurance carrier, and review your dealer agreements to understand exactly where repurchase liability lies. The Dealer’s Advantage Synthetic identities succeed because they look real on paper. Dealers hold an advantage that online lenders do not: the customer is usually standing in the showroom. A current Red Flags program, sound verification tools, trained staff and a disciplined escalation process turn that face-to-face moment into one of the strongest fraud controls in auto finance. © 2026 Law Office of Julie A. Cardosi, P.C. Julie A. Cardosi is an Illinois Attorney and Principal of the private firm, Law Office of Julie A. Cardosi, P.C., of Springfield, Illinois. She has practiced law for over 40 years and represents the business interests of franchised motor vehicle dealers throughout Illinois. Formerly in-house staff General Counsel for the Illinois Automobile Dealers Association, she concentrates her private practice in the areas of dealership compliance matters, franchise law, transfers of ownership, mergers and acquisitions, commercial real estate transfers, dealership employment and other areas impacting day-to-day dealership operations. She also served as Illinois Assistant Attorney General and Deputy Chief of the Consumer Fraud Bureau of the Attorney General’s Office, where she was the primary author of the Illinois Motor Vehicle Advertising Regulations. The material discussed in this article is for general information only and is not intended as legal advice and should not be acted upon as such. Dealers should consult their own private legal counsel for application to their specific circumstances. For more information, Julie can be reached at jcardosi@autocounsel.com or at (217) 787-9782. 15 ILLINOIS AUTOMOBILE DEALER NEWS
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